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California: mob rule on analog opt-out solution?

Yesterday's column, "PG&E Smart Meter Opt-out: Decision By Regulators," looked at salient aspects of the California Public Utilities Commission's proposed decision on PG&E's application for a smart meter opt-out plan. That decision is set to be voted on today.

We noted yesterday the CPUC's stance that residential customers should be able to opt-out "for any reason or for no reason," its findings that smart meters' RF emissions fall well within the guidelines set by the Federal Communications Commission and that opt-outers should pay—but maybe all ratepayers should pay, too, a zany view yet to be finalized.

Today, let's dip back into the CPUC's proposed decision for a closer look at some of the objections to PG&E's suggested solutions and regulators' takes on those objections.

First, the opt-out option deemed most feasible by PG&E is the "radio-off" option, based on smart meters already installed and those purchased and awaiting deployment.

The Utility Reform Network (TURN) responded that that option might address radio frequency (RF) emissions and privacy, but would not resolve concerns about accuracy. (Studies in California, if I'm not mistaken, have already conclusively demonstrated the accuracy of smart meters.)

The EMF Safety Network objects to the "radio-off" option because "there is no assurance that the smart meter is actually turned off." (No telling what tricks the CPUC and PG&E might conspire to pull on the citizenry, right?)

Further, the EMF Safety Network, the Ecological Options Network (EON) and the town of Fairfax, Calif. all seek community-wide opt-out options. That, of course, is a double-edged sword.

Frankly, I doubt that everyone in Fairfax, for instance, is against smart meters and doesn't want access to energy use data, dynamic pricing and the system-wide benefits that include a reduction in greenhouse gas emissions. So is it not somewhat tyrannical to force a community-wide policy? How will citizens who opt out of opting out be treated?

Secondly, until now it's been necessary to consider the costs and loss of benefits that individual opt-out decisions might inflict on an advanced metering infrastructure (AMI) system. Towns or counties selecting a community-wide opt-out option might inflict significantly greater damage to benefits sought and paid for by the vast majority of residential customers—the same folks who voted for California's AB32, which in part prompted the state mandate for smart meters in the first place.

Finally, once political units such as towns and counties seek a community-wide, opt-out option, it begins to smack more of political gamesmanship rather than the ostensible purpose of protecting the health of citizens. Granted, these communities—or, more likely, their politicians—may feel that a grandstanding payback is due PG&E for the latter's heavy-handed tactics in heading off local efforts to secure the option to municipalize electricity services.

As anyone who has read my diatribes about Xcel Energy and Boulder, Colo.'s own municipalization effort knows, I'm against any interference with a community's right to decide its own future. But declaring war on state policies designed to defer capital investment, curb greenhouse gas emissions and offer citizens energy management information and tools is an inappropriate way to hit back at PG&E and self-defeating to boot.

The CPUC's proposed decision noted that "there is a great deal of concern that the radio-off option would not reduce the level of RF emissions." So the commission sought data on "both the average duration and the duration of communications between the electric and gas smart meters with the utility and the level of RF emissions at those times." The commission also sought "information comparing the level of RF emissions from a smart meter with the radio off [option], from a digital meter with no communications capability and from an analog meter."

"One of the more controversial disputes" in the opt-out proceedings was "how many times (average and maximum) an electric smart meter transmits during a 24-hour period," according to the CPUC's proposed decision.

According to PG&E, the cumulative transmission time is 45 seconds per day. Upon examination, the CPUC found, PG&E's response revealed that total average transmission time was 45 seconds, with a maximum of 15 minutes per day. According to PG&E's vendor, Silver Spring Network, a typical smart meter will "communicate" about 45 seconds per day, not 15 minutes. Where the network may not be complete, each meter may attempt to communicate with the network more often, resulting in a maximum transmission time of 15 minutes per day.

This strongly suggests, ironically, that networks—perhaps incomplete due to holes created by residences that opt-out of smart meters—actually emit greater RF than complete networks. So opting out costs all ratepayers in money and system effectiveness, while raising the level of RF emissions.

"Other parties," the CPUC noted, have maintained that the RF transmission by smart meters is constant. More on this canard in a moment.

In response to a request that the FCC step in and order removal of smart meters already installed, that agency noted "the FCC has no data or report to suggest that exposure is occurring at levels of RF energy that exceed our RF exposure guidelines. In contrast, the California Council on Science and Technology recently released a report that found that 'scientific studies have not identified or confirmed negative health effects from potential non-thermal impacts of RF emissions such as those produced by existing, common household electronic devices and smart meters."

Further, the FCC noted, RF emissions by smart meters "produce exposure of no more than 65 percent of the FCC limit at the face of the meter when programmed to transmit continuously. The devices normally transmit for less than one second a few times each day and consumers are normally tens of feet or more from the meter face, so the actual exposures are typically thousands of times less than this 'worse case' measurement condition."

Another issue: do smart meters emit RF emissions when the meter is not transmitting? The answer: yes. Damning? Not at all.

The CPUC's proposed decision noted PG&E's statement that "all digital circuitry—from that contained in clocks, in stereo equipment or in answering machines—emits de minimus RF that is governed by FCC limits for unintentional RF emissions." Values calculated for smart meter certification compared the emissions in the radio-off and radio out (that is, no radio) options. The values show that de minimus RF emissions actually were similar or lower in the radio-off option and both radio-off and radio out emissions are well below the FCC's guidelines. PG&E acknowledged that analog meters emit no RF at all. This, of course, is irrelevant, since many ubiquitous household devices emit the same level of RF as a smart meter with the radio turned off.

The CPUC further noted that the FCC's "authority over technical aspects of radio communications is longstanding and clear" and its responsibilities include regulating RF emissions "to protect public health and safety." Further, the FCC monitors the results of ongoing research in order to maintain the scientific validity of its standards.

Other objections included Fairfax, Calif.'s contention that smart meters violated the Americans with Disabilities Act. Lake County contended that smart meters overburden utility easements. The CPUC batted down these desperate distractions, as it should.

The commission went on to note that "in determining the best opt-out option ... we must balance the concerns expressed by customers against California's overall energy policy."

The proposed decision reiterated that the opt-out option should not preclude the collection of interval data that would support citizens' energy management decisions and participation in, for instance, dynamic pricing and demand response programs. Therefore it favored adoption of "a non-communicating meter—that is, a smart meter with the radio off or a digital meter with no communications capability. This option was proposed to enable customers to take advantage of already deployed energy policies ..."

In the end, however, the CPUC decided that—"in light of parties' comments on the proposed decision" - that it would settle for an analog meter opt-out option subject to further review "to ensure that this option does not impede the full implementation of net metering, demand response and smart grid." And the CPUC chose only one opt-out option, rather than several, for clarity and simplicity of implementation.

I'd have to say, at first blush, that the mob has won a victory here.

Yet to be decided, in a second phase of this proceeding: whether community-wide opt-outs should be allowed, and how the costs incurred by opt-outs should be allocated. I can't wait to hear more arguments that those who refuse to join an effort to modernize the grid, defer capital investment in new power generation and clear the skies and reduce carbon emissions expect the rest of us to pay for their hobbling of the system.

It is said that democracy is a messy business. So be it. Let those who opt-out do so and let them pay the cost, while ensuring that the electorate's self-imposed goals for controlling energy costs, pursuing energy sustainability and lowering energy-related environmental impacts are met. Dissent is always valuable, but its logic should be consistent and transparent. Otherwise, we descend into paralytic bickering and progress towards our society's chosen goals comes grinding to a halt.

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